New ACE Guidance Helps Colleges Navigate Ethics Rules for Campus Visits

ACE has released an updated issue brief outlining the complex federal ethics rules governing such visits.

Federal rules regarding gifts, travel, and meals for officials can be intricate and vary significantly depending on the type of institution and its lobbying status. Navigating these requirements is essential to ensure that relationships with policymakers remain strong while avoiding inadvertent compliance violations.

"Campus invitations have never been more vital," the guidance notes, emphasizing the importance of fostering relationships between campus leaders and federal policymakers to address systemic misconceptions and highlight the sector's contributions.

Key Considerations for Institutions

The ACE brief provides a high-level overview to help institutions understand their obligations in three primary categories:

Public higher education institutions: Generally benefit from specific exemptions regarding gifts and travel for members of Congress, as these are often viewed as government-sponsored activities. However, different, stricter rules apply to executive branch employees.

Private nonprofit institutions with no lobbyists: Must adhere to congressional gift bans with specific exceptions. Privately sponsored travel for members of Congress is possible but requires rigorous pre-approval from the relevant ethics committee and detailed public reporting.

Private institutions with lobbyists: Subject to the strictest standards. The typical "de minimis" gift exceptions-such as small items or meals-often do not apply, and travel sponsorship is subject to tighter limits on duration, lodging, and lobbyist involvement.

Important Compliance Reminders

Registration and disclosure: Institutions registered under the Lobbying Disclosure Act (LDA) must certify twice a year that they have not violated gift and travel rules. They must also disclose expenses related to "honoring events," such as awarding honorary degrees or hosting specific forums.

Institutional training: To avoid awkward or embarrassing situations for visiting officials, institutions should ensure that all staff and student organizations understand that these federal rules apply even to informal invitations, such as a professor inviting an official to speak to a class.

Seek legal counsel: Ethics rules are fluid and fact-specific. ACE strongly encourages institutions to consult with their own legal counsel and the relevant ethics committees-such as the House Committee on Ethics, the Senate Select Committee on Ethics, or the Office of Government Ethics-before extending any invitations to ensure full compliance.